MACAU SAR, CHINA Law and Practice Contributed by: Pedro Cortés, Lektou
• conducting studies and research on gaming-relat- ed issues; • granting licences for casino game promotion activi- ties; • regulating, inspecting, and approving gaming machines, equipment, and systems; • approving equipment and systems for use by casino gaming concessionaires; • encouraging casino gaming concessionaires and gaming promoters to comply with government poli- cies and fulfil social responsibilities; • promoting responsible gambling practices; and • performing other legally mandated responsibilities. Other Agencies In addition to the DICJ, other regulatory entities are empowered to oversee the gaming industry. • Financial Services Bureau (DSF) – responsible for managing and collecting all revenues owed to Macau SAR. In co-ordination with the DICJ, it also has the authority to conduct audits of casino gaming concessionaires and promoters to ensure adherence to financial obligations and regulatory standards. • Judiciary police (PJ) – operate a dedicated unit with exclusive authority to investigate crimes within casinos, other gaming venues, and their surround- ing areas. • Financial Intelligence Office (GIF) – gathers and analyses the information related to potential money laundering and terrorist financing. • Social Welfare Bureau (IAS) – addresses issues related to problem gambling, providing resources and support to mitigate the social impact of gam- bling. • Health Bureau (SS) – responsible for enforcing the casino smoking ban, ensuring compliance with public health regulations in gaming establishments. 4.2 Regulatory Approach Macau’s gaming regulatory framework is a hybrid sys- tem, combining prescriptive requirements with risk- based elements. Embedded within prima facie casino gaming conces- sion contracts, the framework outlines strict guide- lines and operational standards for concessionaires,
promoters, and other industry stakeholders. It man- dates comprehensive regulations for licensing, finan- cial reporting, and operational practices – eg, internal control guidelines of the DICJ – while setting clear expectations for compliance with laws and regula- tions. In parallel, Macau’s model incorporates risk-based regulation, especially in anti-money laundering (AML) and counter-terrorism financing (CTF/CFT). Agencies such as the Financial Intelligence Office apply risk indicators to assess transactions and monitor activi- ties, enabling resource prioritisation toward higher-risk areas and tailored regulatory actions to safeguard the Macau’s gaming industry operates under an admin- istrative concession model, where the government grants concessions to legally incorporated entities through administrative concession contracts. This approach applies to the operation of casino games, lotteries and Chinese and sports lotteries. For casino gaming, concessions are awarded via an international bidding process organised by the Macau SAR govern- ment, and only a maximum of six concessions are permitted under current statutes. To qualify, applicants must be Macau-incorporated limited liability companies with a registered share capital of at least MOP5 billion (USD625 million). The company’s business scope must include casino gam- ing, and a Macau permanent resident must hold at least 15% of the share capital and act as managing director. Applicants, qualified shareholders, directors, and key employees undergo a suitability assessment by the DICJ to ensure they meet stringent legal and financial standards. Financial capacity must be dem- onstrated through guarantees from financial institu- tions or primary shareholders. region’s financial stability. 4.3 Types of Licences In the most recent 2022 international tender, seven entities competed for six available concessions, which were awarded to existing operators Wynn Resorts (Macau) SA, MGM Grand Paradise, SA, Galaxy Casi- no, SA, SJM Resorts, SA, Venetian Macau, SA, and Melco Resorts (Macau), SA. These ten-year contracts
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